State v. Wilson, 2020 Ohio 1136

Wilson was indicted on felonious assault, menacing by stalking, and tampering with evidence; he pled guilty to felonious assault in exchange for nolle prosequi on the other counts.
The trial court accepted the guilty plea on January 10, 2018, and sentenced Wilson to six years’ imprisonment on April 26, 2018.
Wilson failed to file a timely direct appeal; his motion for leave to file a delayed appeal was denied and a subsequent attempted appeal was dismissed.
Wilson filed multiple motions to withdraw his guilty plea post-sentence (October 2018, November 2018, July 2019) and a petition for postconviction relief; he also pointed to a clerical error in the April 26, 2018 journal entry that incorrectly stated the sentence was mandatory.
The trial court corrected the clerical error by nunc pro tunc entry and denied Wilson’s July 10, 2019 motion to withdraw his plea (and related motions); Wilson appealed the denial of the plea-withdrawal motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by denying Wilson’s motion to withdraw his guilty plea without a hearing	The State: Wilson’s post-sentence motion is barred by res judicata; the journal-entry error was clerical and corrected; no facts alleged require withdrawal; a hearing is unnecessary.	Wilson: The original journal entry’s phrasing made the sentence void/mandatory, which he says renders his motion effectively pre-sentence and warrants a hearing; also alleged ineffective assistance.	Court: Affirmed. The error was clerical and corrected; the motion was post-sentence and barred by res judicata; no hearing required absent facts showing manifest injustice.

Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (defines abuse of discretion standard)